Legal Opinion

Vaccaro v. Commissioner

United States Tax Court

Decided July 31, 1972No. Docket No. 6377-69PublishedCited by 18 opinions

During the school year 1966-67 petitioner held a postdoctoral fellowship at the University of Oregon Center for the Advanced Study of Educational Administration in a research program funded primarily through a cost reimbursement contract between the U.S. Office of Education (Department of HEW) and the Board of Higher Education for the State of Oregon. He received a stipend of $ 10,500, and was carried on the payroll as a research associate.

Read the full summary

During the school year 1966-67 petitioner held a postdoctoral fellowship at the University of Oregon Center for the Advanced Study of Educational Administration in a research program funded primarily through a cost reimbursement contract between the U.S. Office of Education (Department of HEW) and the Board of Higher Education for the State of Oregon. He received a stipend of $ 10,500, and was carried on the payroll as a research associate. Petitioner was not required to perform any specific services for the university or the center and did not participate in any of the center's research…

1Opinion of the Court

Drennen, Judge:

Respondent determined deficiencies in petitioners’ Federal income taxes for the taxable years 1966 and 1967 in the amounts of $214.09 and $249.71, respectively.

The only issue for decision is whether payments of U.S. Department of Health, Education, and Welfare funds by the University of Oregon to petitioner Louis C. Vaccaro in the amounts of $1,200 in 1966 and $1,500 in 1967 are excludable from his gross income as amounts received as a fellowship grant within the meaning of section 117 of the 1954 Code.1

FINDINGS OE FACT

The stipulation of facts, together with the exhibits…

2Cases cited10 opinions

  1. Bingler v. JohnsonSupreme Court of the United States · 1969
  2. Reese v. CommissionerUnited States Tax Court · 1966
  3. Joseph D. Woddail and Susan M. Woddail v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1963
  4. Paul j.ussery and Allean M. Ussery v. United StatesCourt of Appeals for the Fifth Circuit · 1961
  5. Turem v. CommissionerUnited States Tax Court · 1970

5 more not listed; retrieve them via the Exa API.

3Cited by18 opinions

  1. Brubakken v. CommissionerUnited States Tax Court · 1976
  2. Bieberdorf v. CommissionerUnited States Tax Court · 1973
  3. Carroll v. CommissionerUnited States Tax Court · 1973
  4. Krupin v. United StatesDistrict Court, E.D. Missouri · 1977
  5. Homer v. CommissionerUnited States Tax Court · 1977

13 more not listed; retrieve them via the Exa API.

Showing a preview — retrieve the full document via the Exa API.

Powered by the Exa API